IN THE CIRCUIT COURT OF PULASKI COUNTY, ARKANSAS
`
`CIVIL DIVISION
`Little Rock Roofing, LL.C Plaintiff
`Vs Case No.:
`Teresa Thomas Defendant
`COMPLAINT
`
`Comes now, Little Rock Roofing, LLC, (“LRR”), by and through its attorney, Jason R Davis
`of the Davis Firm, PLLC, and for its Complaint for breach of contract and unjust enrichment, does
`state as follows:
`
`1. LRR is an Arkansas limited liability company in good standing with its principal place
`of business in Baxter County, Arkansas.
`
`2. Teresa Thomas (“Thomas”) is an Arkansas resident, residing at the Property in Pulaski
`County, Arkansas.
`
`3. This is a breach of contract case arising out of a services contract for roof replacement
`wherein Thomas engaged LRR to replace her roof at 19 Buttermilk Road, in Little Rock, Arkansas,
`which Thomas owns (“Property”).
`
`4. This Court has jurisdiction over this matter and venue is proper.
`
`5. On April 20, 2023, Thomas entered a roofing contract with LRR under which she
`agreed to pay $28,649.49. See Attachment 1, attached hereto and incorporated herein as if set out
`word for word.
`
`6. As of December 6, 2023, $19,793.73, remained unpaid. See Attachment 2, attached
`hereto and incorporated herein as if set out word for word.
`
`7. Subsequent requests for payment have returned void.
`
`Complaint | Page 1 of 3
`
`
`
`
`
`
`
`
`8. The unpaid amount accrues interest at an effective rate of 19.56% per annum (1.5%
`
`per month) until paid in full.
`
`9. Thomas breached her contract with LRR in that:
`a. Thomas knowingly and willfully entered into a contract for roofing services
`with LRR.
`b. LRR executed its obligations under the contract.
`c. Thomas failed to fulfill her obligations under the contract.
`d. Thomas damaged LRR in the amount of $19,793.73 in addition to interest,
`
`and attorney’s fees and costs.
`10. Thomas was unjustly enriched in that:
`a. LRR provided replaced Thomas’s roof to her benefit.
`
`b. Thomas knew that LRR expected to be paid $28,649.49 for the services
`
`provided.
`c. LRR charged a reasonable value for the services and goods provided.
`d. Thomas’s failure to fully pay the expected amount damaged LRR in the
`
`amount of $19,793.73 plus interest and attorney’s fees and costs.
`
`11. Thomas should be found in breach of contract in the amount of $19,793.73; in the
`alternative, find that Thomas was unjustly enriched in the same amount.
`
`12. LRR should be awarded its attorney’s fees and costs.
`
`13. LRR should be awarded pre- and post-judgment interest in the amount of 1.5% per
`month.
`
`Wherefore LRR prays that this honorable Court grant the relief requested herein and for any
`and all just and equitable relief to which it may be entitled.
`
`Respectfully Submitted
`Little Rock Roofing, LL.C
`
`Complaint | Page 2 of 3
`
`
`
`
`
`
`
`
`/s/ Jason R Davis
`Jason R Davis, Ark. Bar No. 2018026
`
`Email: jason@davisfirmpllc.com
`
`Davis Firm, PLLC
`
`300 S. Spring Street, Ste 1004
`Little Rock, Arkansas 72201
`P: (501) 500-3320
`
`Complaint | Page 3 of 3
`
`
`
`
`
`
`
`
`Little Rock Roofing, LLC.
`
`/\ ATTACHMENT
`
`ROOFING
`
`GUALITY YOU CAN TRUSBT
`
`Property Owner
`’fe V€5 a
`
`Address -
`
`1 Roofing 0 Siding 0 Gutters 0 Windows/Doors 0 Insulatio
`
`| Interior 0 Fencing 01 Concrete 0 Other:
`
`Little Rock Roofing will perform the following scope of work:
`
`WOJE pt/ in‘A&/\/&;fijC o L) €. |
`= :E@l Z"‘—-"-‘F-é-i" e us oK =
`
`» S -
`
`—
`
`m— — —————
`
`All applicable labor warranties and lien waiver will be issued at job completion upon final payment.
`
`Exclusions.
`
`Buyer agrees to pay Little Rock Roofing for all labor, materials and services furnished by said contractor, under the terms of this contract:
`Total Price $ 28/6‘7'4. ‘/7
`
`Down Payment received : Check # S
`Balance Due Upon Completion $
`
`Little Rock Roofing shall not be liable for delays caused by strike, weather conditions, delay in obtaining goods or other causes beyond
`
`3.
`the contract.
`
`b This contract, which includes the terms and conditions set forth on the reverse side, contains the entire understanding and agreement
`between parties No verbal agreements or changes are to be recognized. This agreement Is subject to office approval.
`
`c. Owners certify that they have not been given or promised a cash payment or rebate, nor has it been represented to owners that they
`
`will receive a cash bonus commissicn on future sales as an inducement for the consummation of this transaction.
`Owner agrees that he or she has read this agreement, fully understands its provisions and has been given an exact and fully completed copy
`
`of this contract.
`
`Customer Signature’ O— w Date:_'q/gr_a_D ()9\5“~ =
`
`Rep:esontatnve:_% W_ R I Date: %/ZQ/L 5
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`INVOICE
`
`Little Rock Roofing Sales Representative
`
`5301 Warden Rd, Suite I-4 Rene Webb %’\
`North Little Rock, AR 72116 (501 203-9229 LITTLE ROCK
`
`(501) 203-9229 info@littlerockroofing.us ROOFING
`
`GUALITY YOU CAN TRUST
`501-203-9229
`
`FREE INSPECTIONS!
`
`Teresa Thomas
`
`19 Buttermilk Road Invoice # 1275
`Little Rock, AR Date 12/6/2023
`Amount Due $19,793.73
`Due Date Due on Receipt
`Item Description Amount
`Home Re-Roof shingles 2600 sqft @10% waste $7,566.00
`
`Ridge Shingle 81LF $259.00
`
`Synthetic Felt Synthetic existing $832.00
`R&R
`2600 sqft
`
`Drip Edge 138 LF $335.00
`
`ATTACHMENT
`2
`
`Pipe Flashing 5 Shingle pipe flashing
`
`
`
`
`
`
`
`
`Item
`
`750 vent
`
`Turbine
`
`Skylight Reflash
`
`Vent Cap, Flashing, Pipe
`
`Description
`
`1 box/750 vent
`
`2 turbine vents
`
`1 Skylight light reflash with rolled roofing on shingle roof
`
`R&R 3" damaged from tornado
`
`R&R 4" damaged from tornado
`
`Amount
`
`$65.70
`
`$190.00
`
`$155.90
`
`$155.00
`
`$154.00
`
`
`
`
`
`
`
`
`Item Description Amount
`
`TPO System R&R 660 sq ft TPO $4,290.00
`
`Drip Edge $1,352.61
`Pipe Flashing TPO 1 pipe flashing $76.00
`Skylight R&R 2 domed skylights front of house $0.00
`Skylight Reflash TPO reflash 5 skylights $779.50
`
`ISO Taper R&R Q panel for ISO $112.86
`
`
`
`
`
`
`
`
`Item Description Amount
`
`Dump Fee Dump fee for debris $956.16
`
`Framing Demo and rebuild $1,744.00
`2x6 truss 2x4 bracing 2x4 edge, 1x6 facia
`
`Decking $525.00
`
`Chimney Repair TBD see email $0.00
`
`
`
`
`
`
`
`
`Item Description Amount
`
`Sub Total $19,793.73
`Total $19,793.73
`Amount Paid $0.00
`Balance Due $19,793.73
`
`*Card payment may incur a convenience fee
`which is calculated at checkout.
`
`Make a payment >
`
`fl Verified secure
`
`SPECIAL INSTRUCTIONS
`
`
`
`
`
`
`
`
`
`
`
`CIVIL DIVISION
`Little Rock Roofing, LL.C Plaintiff
`Vs Case No.:
`Teresa Thomas Defendant
`COMPLAINT
`
`Comes now, Little Rock Roofing, LLC, (“LRR”), by and through its attorney, Jason R Davis
`of the Davis Firm, PLLC, and for its Complaint for breach of contract and unjust enrichment, does
`state as follows:
`
`1. LRR is an Arkansas limited liability company in good standing with its principal place
`of business in Baxter County, Arkansas.
`
`2. Teresa Thomas (“Thomas”) is an Arkansas resident, residing at the Property in Pulaski
`County, Arkansas.
`
`3. This is a breach of contract case arising out of a services contract for roof replacement
`wherein Thomas engaged LRR to replace her roof at 19 Buttermilk Road, in Little Rock, Arkansas,
`which Thomas owns (“Property”).
`
`4. This Court has jurisdiction over this matter and venue is proper.
`
`5. On April 20, 2023, Thomas entered a roofing contract with LRR under which she
`agreed to pay $28,649.49. See Attachment 1, attached hereto and incorporated herein as if set out
`word for word.
`
`6. As of December 6, 2023, $19,793.73, remained unpaid. See Attachment 2, attached
`hereto and incorporated herein as if set out word for word.
`
`7. Subsequent requests for payment have returned void.
`
`Complaint | Page 1 of 3
`
`
`
`
`
`
`
`
`8. The unpaid amount accrues interest at an effective rate of 19.56% per annum (1.5%
`
`per month) until paid in full.
`
`9. Thomas breached her contract with LRR in that:
`a. Thomas knowingly and willfully entered into a contract for roofing services
`with LRR.
`b. LRR executed its obligations under the contract.
`c. Thomas failed to fulfill her obligations under the contract.
`d. Thomas damaged LRR in the amount of $19,793.73 in addition to interest,
`
`and attorney’s fees and costs.
`10. Thomas was unjustly enriched in that:
`a. LRR provided replaced Thomas’s roof to her benefit.
`
`b. Thomas knew that LRR expected to be paid $28,649.49 for the services
`
`provided.
`c. LRR charged a reasonable value for the services and goods provided.
`d. Thomas’s failure to fully pay the expected amount damaged LRR in the
`
`amount of $19,793.73 plus interest and attorney’s fees and costs.
`
`11. Thomas should be found in breach of contract in the amount of $19,793.73; in the
`alternative, find that Thomas was unjustly enriched in the same amount.
`
`12. LRR should be awarded its attorney’s fees and costs.
`
`13. LRR should be awarded pre- and post-judgment interest in the amount of 1.5% per
`month.
`
`Wherefore LRR prays that this honorable Court grant the relief requested herein and for any
`and all just and equitable relief to which it may be entitled.
`
`Respectfully Submitted
`Little Rock Roofing, LL.C
`
`Complaint | Page 2 of 3
`
`
`
`
`
`
`
`
`/s/ Jason R Davis
`Jason R Davis, Ark. Bar No. 2018026
`
`Email: jason@davisfirmpllc.com
`
`Davis Firm, PLLC
`
`300 S. Spring Street, Ste 1004
`Little Rock, Arkansas 72201
`P: (501) 500-3320
`
`Complaint | Page 3 of 3
`
`
`
`
`
`
`
`
`Little Rock Roofing, LLC.
`
`/\ ATTACHMENT
`
`ROOFING
`
`GUALITY YOU CAN TRUSBT
`
`Property Owner
`’fe V€5 a
`
`Address -
`
`1 Roofing 0 Siding 0 Gutters 0 Windows/Doors 0 Insulatio
`
`| Interior 0 Fencing 01 Concrete 0 Other:
`
`Little Rock Roofing will perform the following scope of work:
`
`WOJE pt/ in‘A&/\/&;fijC o L) €. |
`= :E@l Z"‘—-"-‘F-é-i" e us oK =
`
`» S -
`
`—
`
`m— — —————
`
`All applicable labor warranties and lien waiver will be issued at job completion upon final payment.
`
`Exclusions.
`
`Buyer agrees to pay Little Rock Roofing for all labor, materials and services furnished by said contractor, under the terms of this contract:
`Total Price $ 28/6‘7'4. ‘/7
`
`Down Payment received : Check # S
`Balance Due Upon Completion $
`
`Little Rock Roofing shall not be liable for delays caused by strike, weather conditions, delay in obtaining goods or other causes beyond
`
`3.
`the contract.
`
`b This contract, which includes the terms and conditions set forth on the reverse side, contains the entire understanding and agreement
`between parties No verbal agreements or changes are to be recognized. This agreement Is subject to office approval.
`
`c. Owners certify that they have not been given or promised a cash payment or rebate, nor has it been represented to owners that they
`
`will receive a cash bonus commissicn on future sales as an inducement for the consummation of this transaction.
`Owner agrees that he or she has read this agreement, fully understands its provisions and has been given an exact and fully completed copy
`
`of this contract.
`
`Customer Signature’ O— w Date:_'q/gr_a_D ()9\5“~ =
`
`Rep:esontatnve:_% W_ R I Date: %/ZQ/L 5
`
`
`
`
`
`
`
`
`
`ACTION
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`
`
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`
`
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`
`ACTION
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`ACTION
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`]
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`o ® g
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`ACTION
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`e
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`ACTION
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`
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`
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`
`
`=) &2
`
`
`
`
`
`
`
`
`=) &2
`
`
`
`
`
`
`
`
`=) &2
`
`
`
`
`
`
`
`
`ZRes
`
`
`
`
`
`
`
`
`
`INVOICE
`
`Little Rock Roofing Sales Representative
`
`5301 Warden Rd, Suite I-4 Rene Webb %’\
`North Little Rock, AR 72116 (501 203-9229 LITTLE ROCK
`
`(501) 203-9229 info@littlerockroofing.us ROOFING
`
`GUALITY YOU CAN TRUST
`501-203-9229
`
`FREE INSPECTIONS!
`
`Teresa Thomas
`
`19 Buttermilk Road Invoice # 1275
`Little Rock, AR Date 12/6/2023
`Amount Due $19,793.73
`Due Date Due on Receipt
`Item Description Amount
`Home Re-Roof shingles 2600 sqft @10% waste $7,566.00
`
`Ridge Shingle 81LF $259.00
`
`Synthetic Felt Synthetic existing $832.00
`R&R
`2600 sqft
`
`Drip Edge 138 LF $335.00
`
`ATTACHMENT
`2
`
`Pipe Flashing 5 Shingle pipe flashing
`
`
`
`
`
`
`
`
`Item
`
`750 vent
`
`Turbine
`
`Skylight Reflash
`
`Vent Cap, Flashing, Pipe
`
`Description
`
`1 box/750 vent
`
`2 turbine vents
`
`1 Skylight light reflash with rolled roofing on shingle roof
`
`R&R 3" damaged from tornado
`
`R&R 4" damaged from tornado
`
`Amount
`
`$65.70
`
`$190.00
`
`$155.90
`
`$155.00
`
`$154.00
`
`
`
`
`
`
`
`
`Item Description Amount
`
`TPO System R&R 660 sq ft TPO $4,290.00
`
`Drip Edge $1,352.61
`Pipe Flashing TPO 1 pipe flashing $76.00
`Skylight R&R 2 domed skylights front of house $0.00
`Skylight Reflash TPO reflash 5 skylights $779.50
`
`ISO Taper R&R Q panel for ISO $112.86
`
`
`
`
`
`
`
`
`Item Description Amount
`
`Dump Fee Dump fee for debris $956.16
`
`Framing Demo and rebuild $1,744.00
`2x6 truss 2x4 bracing 2x4 edge, 1x6 facia
`
`Decking $525.00
`
`Chimney Repair TBD see email $0.00
`
`
`
`
`
`
`
`
`Item Description Amount
`
`Sub Total $19,793.73
`Total $19,793.73
`Amount Paid $0.00
`Balance Due $19,793.73
`
`*Card payment may incur a convenience fee
`which is calculated at checkout.
`
`Make a payment >
`
`fl Verified secure
`
`SPECIAL INSTRUCTIONS
`
`
`
`
`
`
`
`
`
`
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